The Disclosure (Scotland) Act 2020 (Disclosure Act) is now live!

April 2nd 2025

There are big changes for voluntary sector organisations as a result of the Disclosure (Scotland) Act 2020.

Key updates include:

Membership of the PVG scheme will be a legal requirement from 1st April 2025 for those carrying out a regulated role. There will be a 3-month grace period from the 1st April, 2025 – 30th June, 2025 to apply for membership of the PVG scheme where required.
The concept of ‘regulated work’ has been replaced with ‘regulated roles’, making it more easily understood. This includes roles for charity trustees and board or committee members.

Here's a quick reminder of what you need to know:

The Disclosure Act improves the disclosure system in Scotland by removing unnecessary barriers for people with convictions as they seek employment or other opportunities, and enhances the PVG scheme.

Key changes under the Disclosure Act include:

Membership of the PVG scheme is now a legal requirement for those carrying out a regulated role.
They have replaced the concept of ‘regulated work’ with ‘regulated roles’.
There is a 3-month grace period from the 1st April 25 – 30th June 25 for PVG scheme applications to be submitted for individuals who are currently in a regulated role.
Simplified disclosure products and people having more control over their information.
An individualised approach to the disclosure of childhood offending and rights of review for convictions disclosed, to enhance fairness and proportionality.
The ability for Disclosure Scotland to impose conditions on PVG scheme members who are under consideration for listing.

Grace Period

There is a short grace period of three months after the PVG scheme becomes a legal requirement on 1st April 2025. This will ensure individuals and organisations don’t immediately commit an offence if there are individuals who are not yet PVG scheme members but are currently working in regulated roles.

Individuals and organisations will not commit an offence if an individual who is carrying out a regulated role for them has, before the 1 July 2025, made an application to join the PVG Scheme, even if Disclosure Scotland has not issued the result.

From 1st July 2025 onwards, two new offences will come into force. It will become an offence for:

anyone carrying out a regulated role to do so whilst not a member of the PVG scheme
organisations to offer any type of regulated role to an individual unless they have received a PVG scheme disclosure.

Regulated Roles

From 1st April 25, ‘regulated work’ will be replaced by ‘regulated roles’. It is expected that roles which were included under regulated work, will also be regulated roles. However, the introduction of ‘regulated roles’ will also bring new roles into the PVG scheme that were not eligible before the 1st April 2025. Examples include, football agents, talent scouts, hypnotherapists and certain hospital or hospice-based roles.

To help you assess the criteria for regulated roles, you can review the following documents on the Volunteer Scotland Website to help you decide the PVG schemes required:

If you are in a regulated role, you must become a member of the PVG scheme.

To check out if roles in your organisation/group need to be members of the PVG and for more information, guidance and support please click on the links below for Volunteer Scotland and Disclosure Scotland: